The assessee had given a detailed chart regarding payments made towards advertisement expenditure, legal and professional fees and service charges. At appropriate places, the assessee also obtained certificate from the payee for lower withholding tax and deducted taxes at the rates mentioned in the certificate. The Principal Commissioner may be of the opinion that the estimate made by the officer was on the lower side but that would not vest the Commissioner with power to re-visit the entire assessment and determine the income himself at a higher figure. It was not the case of the Principal Commissioner that the Assessing Officer had failed to apply his mind to the issues on hand or had omitted to make enquiries altogether or had taken a view which was not legally plausible in the instant facts. Further, the assessee gave a complete reconciliation on the deduction of tax at source on various payments made and gave a detailed explanation on applicability of deduction of tax at source with respect to various payments with the applicable rate. Section 263 of the Act does not visualise a case of substitution of the judgment of the Commissioner for that of the Assessing Officer, who passed the order unless the decision is held to be wholly erroneous. The revision is  not sustainable.(AY.2017-18)